Horton v. California

Horton v. California, 496 U.S. 128 (1990), was a United States Supreme Court case that developed the plain view doctrine under the Fourth Amendment to the United States Constitution. The Supreme Court had already recognized the doctrine in Coolidge v. New Hampshire (1971) and in Arizona v. Hicks (1987), but expanded it in Horton. That expansion included a three-part test, requiring that the police officer finding evidence in plain view be:

  1. lawfully present at the place where the evidence can be plainly viewed,
  2. the officer must have a lawful right of access to the object, and
  3. the incriminating character of the object must be “immediately apparent.”

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